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Comment

I applaud the efforts of all parties to restructure the algorithms to enable a more accurate scoring model. I like to keep things simple so I would like to start out by saying if the fico system is not broken do not fix it.
If changing to Fico 9, scores will become a better indicator, business processes that use credit scores will not have to change. I personally have seen too many people negatively effected by erroneous collection data, especially medical collections, not to applaud that change.
Changing to a vantagescore only system would be absolutely terrifying. Not only would all the systems have to be updated. It would basically give 3 companies the power to control our economy
Option 1 Keeping a single score would be best. If the sole purpose of this initiative is how to score more of the population, may i suggest as part of the Fico company continuing its monopoly, they should be required to better inform the general public how to generate a score.
Option 2 . It falls under if it ain't broke don't fix it category.
Option 3 I do not understand any advantage that this option would provide. Since a 620 with fico and a 620 with vantagescore do not mean the same thing. It would not keep underwriting standards consistent throughout the industry. I think this option would not only be cost prohibitive to the whole mortgage industry; it would be confusing to the public as well. The risk of adverse selection is too high and not good for the industry
option 4. Where a lender could use a vantagescore, if and only if a fico score was not available or generated is not a terrible idea. This would also be in keeping with what I interpreted as one of the key purposes of this request for input, the ability to score more of the population.